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NACUBO, joined by 10 associations, responded to the November 17 request for comments by the IRS, seeking regulatory modifications or waivers from requirements that could assist taxpayers with economic recovery from the pandemic. The notice originated with a May 19 executive order directing agencies to consider principles of fairness in administration enforcement during the current crisis.

Highlighting the logistical hurdles in garnering in-person or “wet” signatures, NACUBO’s December 11 letter pushed for acceptance of electronic signatures at a time when campus business office staff are working remotely. 

NACUBO also pushed for filing deadlines to be extended for Forms 990- and 990-T, as well as for all IRS notices colleges and universities may receive, as they pertain to previous time periods that typically require staff to visit campus offices to properly research before responding.

The IRS is accepting comments at until January 1, 2021.


Mary Bachinger

Director, Tax Policy


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